Quasi-judicial officers may face discipline only for culpable negligence or bias, with jurisdictional objections decided first.

Disciplinary action against a quasi-judicial income-tax appellate authority is permissible only where the charge shows more than an adverse legal view, and must disclose culpable negligence, recklessness, lack of bona fides, bias, malice, illegality or conduct unbecoming of a government servant. Applying that standard, the Court found one charge to be prima facie capable of sustaining inquiry, but held that the petitioner's jurisdictional objections to initiation of proceedings, including objections arising from the appellate order and vigilance guidelines, had not been finally decided. The disciplinary authority was therefore required to examine those objections and pass a reasoned final order before concluding the departmental process.

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Issues: Whether the charge memorandum issued against a quasi-judicial income-tax appellate authority was liable to be quashed, and whether the disciplinary authority was required to first consider the jurisdictional objections raised against initiation of disciplinary proceedings.

Analysis: The governing principle is that officers discharging judicial or quasi-judicial functions are not immune from disciplinary action, but such action cannot rest on a mere error of judgment or incorrect view of law. A charge can sustain only where the material indicates culpable negligence, recklessness, lack of bona fides, extraneous consideration, malice, bias, illegality, or conduct unbecoming of a government servant. The allegations in the charge memorandum were examined in that light. While one charge was found to prima facie suggest culpable negligence, the Court considered that the broader jurisdictional objections raised by the petitioner, including the effect of the appellate order and the applicability of the vigilance guidelines, had not been finally adjudicated by the disciplinary authority. Since the disciplinary process had reached the stage of inquiry report and UPSC advice, the Court held that the authority itself should first examine those objections and decide the matter by a reasoned order.

Conclusion: The charge memorandum was not quashed, but the disciplinary authority was directed to consider the petitioner's jurisdictional pleas and pass a reasoned final order in accordance with law.

Ratio Decidendi: Disciplinary proceedings against a quasi-judicial officer are sustainable only when the charge discloses something more than an adverse adjudicatory view, such as culpable negligence or extraneous influence, and jurisdictional objections to initiation must be considered before final departmental action is concluded.

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